MR. CHIEF JUSTICE WARREN delivered the opinion of the Court.
The question presented is whether a Federal District Court has jurisdiction under 28 U. S. C. § 1346 (a) (1) of a suit by a taxpayer for the refund of income tax payments which did not discharge the entire amount of his assessment.
This is our second consideration of the case. In the 1957 Term, we decided that full payment of the assessment is a jurisdictional prerequisite to suit,
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